So says Eric J. Sinrod, a California attorney who criticizes the courts for taking e-discovery requirements to extreme lengths.
I have found the best course is to find out what sort of electronic data exists, and early–at the 26(f) meeting with opposing counsel, if possible. With that knowledge, I can make an intelligent decision as to whether I actually need things like meta data, or whether printouts of the electronic data will satisfy my needs.
But this will not handle every situation, of course, and I can think of many situations in which discovery costs could skyrocket due to e-discovery requirements.
Have you run into e-discovery issues? How have you handled them?